Document gDpNNN6Rej7xZ7jwRBNROmV4q

broad, burdensome, harassing, excessive in scope and time and incorrectly implying that its products were a health hazard. INTERROGATORY NO. 30: Identify any and all persons or entities, other than the employees listed above, including, but not limited to insurance carriers and/or related companies, which provided services, information, consulting and/or advice to defendant and/or any predecessor/related entity, at any time from 1940 to date, relating to any and/or all of the following: (a) Occupational health and/or safety; (b) Federal, state and/or local safety regulations (including, but limited to OSHA); (c) Federal, state regulations ,- and/or local environmental (d) Federal, state and/or local health regulations (including, but.limited to OSHA)? (e) Industrial hygiene; (f) Insurance or risk management; (g) Workers compensation; (h) Medical matters; and, (h) Asbestos abatement. ANSWER: - Gleason objects to this Interrogatory as overly broad, burdensome, harassing, excessive in scope time and incorrectly implying that its products were a health hazard. and INTERROGATORY NO, 31: Did defendant and/or any predecessor/related entity, or any medical department or industrial hygiene division thereof, maintain a medical and/or scientific library at any time from 1940 to the present? If so: GLEASON-000028